Emami Paper Mills Ltd Directors Report.

To the Members of

EMAMI PAPER MILLS LIMITED

Report on the IndAS Financial Statements

We have audited the accompanying Ind AS ! nancial statements of EMAMI PAPER MILLS LIMITED ("the Company"), which comprise the Balance Sheet as at 31st March, 2019, and the Statement of Pro! t and Loss (including Other Comprehensive Income), the Cash Flow Statement and the Statement of Changes in Equity for the year then ended, and a summary of the signi! cant accounting policies and other explanatory information.

Opinion

In our opinion and to the best of our information and according to the explanations given to us, the aforesaid Ind AS ! nancial statements give the information required by the Act in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India, of the ! nancial position of the Company as at 31st March, 2019, and its pro! t, total comprehensive income, its cash " ows and the changes in equity for the year ended on that date.

Basis for Opinion

We conducted our audit in accordance with the Standards on Auditing (SAs) speci! ed under section 143(10) of the Companies Act, 2013. We are independent of the Group in accordance with the Code of Ethics issued by the Institute of Chartered Accountants of India, and we have ful! lled our other ethical responsibilities in accordance with the provisions of the Companies Act, 2013. We believe that the audit evidence we have obtained is su# cient and appropriate to provide a basis for our opinion.

Key Audit Matters

Key audit matters are those matters that, in our professional judgment, were of most signi! cance in our audit of the ! nancial statements of the current ! nancial year. These matters were addressed in the context of our audit of the ! nancial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.

1. New Regulation-Timing of Revenue Recognition

Key Audit Matter Response to KAM
Accuracy of recognition, measurement, presentation and Principal Audit Procedures disclosures of revenues and other related balances in view Ind AS 115 "Revenue from Contracts with Customers" impact of adoption of (new revenue accounting standard) We assessed the Companys process to identify the of adoption of the new revenue accounting standard.
The application of the new revenue accounting standard involves certain key judgements relating to identi!cation of distinct performance obligations, determination of transaction price of the identi!ed performance obligations, the appropriateness of the basis used to measure revenue recognized over a period or on point in time. Additionally, new revenue accounting standard contains disclosures which involves collation of information in respect of disaggregated revenue and periods over which the remaining performance obligations will be satis!ed subsequent to the balance sheet date. Our audit approach consisted testing of the design and operating effectiveness of the internal controls and substantive testing.
If a performance obligation is not satis!ed over time, an entity satisfied the performance obligation at a point in time. To determine the point in time at which a customer obtains control of a promised asset and the entity satisfied a performance obligation, the entity shall consider the requirements for control and shall consider indicators of the transfer of control, Sample of revenues disaggregated by type and service offerings was tested with the performance obligations specified in the underlying contracts.
Performed analytical procedures for reasonableness of revenues disclosed by type and service offerings.
We reviewed the collation of information and the logic of the report generated used to prepare the disclosure relating to the periods over which the remaining performance obligations will be satis!ed subsequent to the balance sheet date.
which include, but are not limited to (a) The entity has a present right to payment for the asset (b) The customer has legal title to the asset (c) The entity has transferred physical possession of the asset (d) The customer has the signi!cant risks and rewards of ownership of the asset (e) The customer has accepted the asset We reviewed the incidence of transfer of control through satisfaction of performance obligation and the point of time at which the right to payment occurs.
Conclusion
The assumption applied by the company were taken into consideration and we agree with management evaluations.
2. Input Tax Credit
Key Audit Matter Response to KAM
Non reconciliation of Input Tax Credit receivable with GSTR-2A Principal Audit Procedures
The Company has accounted for Input Tax Credit on the basis of invoices received from suppliers of goods and services. However, some of these suppliers are yet to !le GSTR-1 re"ecting the supplies made by them to the company leading to di$erences between credit recognized by the company and that shown in GSTR 2A. We have checked the GSTR-1 and GSTR-3B !led by the Company and vouched a sample population of Invoices on the basis of invoices received from suppliers Input Tax Credit was accounted for .
The company is in the process of reconciling the GST Input Tax credit for the years 2017-18 and 2018-19. However, this process cannot be completed till an end date being declared by authorities for !ling GSTR1 for a particular period. In view of the present scenario and the various changes being implemented in the GST law, it was found prudent not to account for the di$erence till the situation crystallizes.
Conclusion
The assumption applied by the company were taken into consideration and we agree with management evaluations.
3. Interest Rate Risk Mitigation
Key Audit Matter Response to KAM
The company uses derivative financial instruments to hedge interest rate risks arising from loans taken in the ordinary course of business. Managements hedging policy is documented in corresponding internal guidelines and serves as the basis for these transactions. The means of limiting this risk include entering into cross-currency interest rate swaps. The companies enter into interest rate hedges for the purpose of achieving an economically sensible ratio of "oating to !xed interest rate exposures. As a part of our audit procedures, among other things we assessed the contractual and financial parameters and evaluated the accounting treatment, including the effects on equity and pro!t or loss, of the various hedging relationships.
Conclusion
We agree with managements evaluation.
Asset/(Liability) in respect of those interest rate swaps are measured at fair value (i.e. Mark To Market value). Any change in Mark To Market value of those swaps are recognized in Other Comprehensive Income when those qualify for hedge accounting and designated as hedge instrument by the company; in other cases, the change in Mark To Market value is recognized in Pro!t and Loss Statement. Accordingly, the company is carrying interest rate swap assets of INR 6.18 Crores and interest rate swap liability of INR 4.02 Cr as at 31.03.19; the change in fair value amounting to INR 4.68 Cr is recognized in Other Comprehensive Income and that amounting to INR 2.43 Cr is recognized in Pro!t and Loss Statement. We also evaluated the Companys internal control system with regard to derivative financial instruments, including the internal activities to monitor compliance with the hedging policy. In addition to evaluating the internal control system, we obtained bank con!rmations for the hedging instruments in order to assess completeness. With regard to the expected cash flows and the assessment of the e$ectiveness of hedges, we essentially conducted a retrospective assessment of past hedging levels. In doing so, we were able to satisfy ourselves that the estimates and assumptions made by management were substantiated and sufficiently documented.

 

4. Foreign Currency Exposure-Currency Swaps
Key Audit Matter Response to KAM
The company has earned a gain of Rs. 2.70 Crores from fair value (MTM Value) change in Currency Swaps which is recognized in Pro!t and Loss Statement. The company has liability of INR 4.48 Crores as at 31.03.19 which is measured at MTM value. MTM asset/(Liability) are measured at fair value as of the balance sheet date. For Currency rate Swaps, the negative Fair Values as of the Balance Sheet date amount to Rs. 4.48 Crores. Principal Audit Procedures
As a part of our audit procedures, we assessed the contractural and financial parameters and evaluated the accounting treatment, including the effects on equity and pro!t or loss, and the rationale behind not designating derivative as hedge. For the purpose of auditing the fair value mesurement of financial instruments, we also assessed the methods of calculation employed on the basis of market data. In addition to evaluating the internal control system, we obtained bank con!rmations for the derivative instruments in order to assess completeness.
On the basis of principle of conservatism, it would had been more appropriate and rationale to designate these derivatives as hedged instruments.
Conclusion
The assumption applied by the company were taken into consideration and we agree with management evaluations.

Information Other than the Financial Statements and Auditors Report Thereon

• The Companys Board of Directors is responsible for the other information. The other information comprises the information included in the Annual Report, for example, Corporate Overview, Key Highlights, Board of Directors Report, Report on Corporate Governance, Management Discussion & Analysis Report, Business Responsibility Report, etc., but does not include the financial statements and our auditors report thereon.

• Our opinion on the financial statements does not cover the other information and we do not express any form of assurance conclusion thereon.

• In connection with our audit of the financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained during the course of our audit or otherwise appears to be materially misstated.

• If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact. We have nothing to report in this regard.

Responsibilities of the Management and Those Charged with Governance for the Financial Statements

The Companys Board of Directors is responsible for the matters stated in Section 134(5) of the Companies Act, 2013 ("the Act") with respect to the preparation of these Ind AS financial statements that give a true and fair view of the financial position, financial performance including other comprehensive income, cash flows and changes in equity of the Company in accordance with the accounting principles generally accepted in India, including the Indian Accounting Standards (Ind AS) prescribed under Section 133 of the Act.

This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making judgements and estimates that are reasonable and prudent; and design, implementation and maintenance of adequate internal financial controls, that were operating e$ectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the Ind AS financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

Auditors Responsibility

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditors report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with SAs will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to in"uence the economic decisions of users taken on the basis of these annual financial statements.

As part of an audit in accordance with SAs, we exercise professional judgment and maintain professional skepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the financial statements, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.

• Obtain an understanding of internal controls relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on whether the Company has in place an adequate internal financial controls system over financial reporting and the operating effectiveness of such controls.

• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by management.

• Conclude on the appropriateness of managements use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast signi!cant doubt on the ability of the company to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditors report to the related disclosures in the financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditors report. However, future events or conditions may cause the company to cease to continue as a going concern.

• Evaluate the overall presentation, structure and content of the financial statements, including the disclosures, and whether the financial statements represent the underlying transactions and events in a manner that achieves fair presentation.

We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and signi!cant audit !ndings, including any signi!cant de!ciencies in internal control that we identify during our audit. We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, related safeguards. From the matters communicated with those charged with governance, we determine those matters that were of most signi!cance in the audit of the financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditors report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be communicated in our report because the adverse consequences of doing so would reasonably be expected to outweigh the public interest bene!ts of such communication.

Report on other Legal and Regulatory Requirements

1. As required by Section 143(3) of the Act, based on our audit, we report to the extent applicable that:

a) We have sought and obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purposes of our audit.

b) In our opinion, proper books of accounts as required by law have been kept by the Company so far as it appears from our examination of those books.

c) The Balance Sheet, the Statement of Pro!t and Loss and the Cash Flow Statement dealt with by this Report are in agreement with the relevant books of accounts.

d) In our opinion, the aforesaid financial statements comply with the Accounting Standards prescribed under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014.

e) On the basis of the written representations received from the Directors as on 31st March, 2019 taken on record by the Board of Directors, none of the Directors is disquali!ed as on 31st March, 2019 from being appointed as a director in terms of Section 164(2) of the Act.

f) With respect to the adequacy of the internal financial controls over financial reporting of the Company and the operating effectiveness of such controls, refer to our separate report in "Annexure A". Our report expresses an unmodi!ed opinion on the adequacy and operating effectiveness of the Companys internal financial controls over financial reporting.

g) With respect to the other matters to be included in the Auditors Report in accordance with the requirements of Section 197(16) of the Act, as amended:

In our opinion and to the best of our information and according to the explanation given to us, the remuneration paid by the company to its directors during the year is in accordance with the provision of Section 197 of the Act.

h) With respect to the other matters to be included in the Auditors Report in accordance with the Rule 11 of the Companies (Audit and Auditors) rules, 2014, in our opinion and to the best of our information and according to the explanations given to us:

i. The Company has disclosed the impact of pending litigations on its financial position in its financial statements.

ii. The Company has made provision, as required under the applicable law or accounting standards, for material foreseeable losses on long term contracts including derivative contracts.

iii. There has been no delay in transferring amounts, which were required to be transferred to the Investor education and Protection Fund by the Company.

2. As required by the Companies (Auditors Report) Order, 2016 ("the Order") issued by the Central Government of India in terms of sub-section (11) of section 143 of the Act, we give in "Annexure B", a statement on the matters specified in paragraphs 3 and 4 of the Order, to the extent applicable.

For Agrawal Subodh & Co.
Chartered Accountants
Firms Registration No : 319260E
Subodh Kumar Agrawal
Place: Kolkata Partner
Date: 08th May, 2019. Membership No. : 054670

Annexure "A" to the Independent Auditors Report

(Referred to in paragraph 1(f) under ‘Report on Other Legal and Regulatory Requirements Section of our report of even date)

Report on the Internal Financial Controls Over Financial Reporting under Clause (i) of Sub-section 3 of Section 143 of the Companies Act, 2013 ("the Act").

We have audited the internal financial controls over financial reporting of Emami Paper Mills Limited ("the Company") as of 31st March, 2019 in conjunction with our audit of the Ind AS financial statements of the Company for the year ended on that date.

Managements Responsibility for Internal Financial controls

The Companys management is responsible for establishing and maintaining internal financial controls based on the internal control over financial reporting criteria established by the Company considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting issued by the Institute of Chartered Accountants of India.

These responsibilities include the design, implementation and maintenance of adequate internal financial controls that were operating e$ectively for ensuring the orderly and e#cient conduct of its business, including adherence to companys policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information, as required under the Companies Act, 2013.

Auditors Responsibility

Our responsibility is to express an opinion on the Companys internal financial controls over financial reporting based on our audit. We conducted our audit in accordance with the Guidance Note on Audit of Internal Financial Controls over Financial Reporting (the "Guidance Note") issued by the Institute of Chartered Accountants of India and the Standards on Auditing, prescribed under Section 143(10) of the Companies Act, 2013, to the extent applicable to an audit of internal financial controls. Those Standards and the Guidance Note require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether adequate internal financial controls over financial reporting was established and maintained and if such controls operated e$ectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy of the internal financial controls system over financial reporting and their operating effectiveness. Our audit of internal financial controls over financial reporting included obtaining an understanding of internal financial controls over financial reporting, assessing the risk that a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. The procedures selected depend on the auditors judgement, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion on the Companys internal financial controls system over financial reporting.

Meaning of Internal Financial Controls over Financial Reporting

A companys internal financial control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A companys internal financial control over financial reporting includes those policies and procedures that

(1) Pertain to the maintenance of records that, in reasonable detail, accurately and fairly re"ect the transactions and dispositions of the assets of the company;

(2) Provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and

(3) Provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the Companys assets that could have a material e$ect on the financial statements.

Inherent Limitations of Internal Financial Controls over Financial Reporting

Because of the inherent limitations of internal financial controls over financial reporting, including the possibility of collusion or improper management override of controls, material misstatements due to error or fraud may occur and not be detected. Also, projections of any evaluation of the internal financial controls over financial controls over financial reporting to future periods are subject to the risk that the internal financial control over financial reporting may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Opinion

In our opinion, the Company has, in all material respects, an adequate internal financial controls system over financial reporting and such internal financial controls over financial reporting were operating e$ectively as at 31st March 2019, based on the internal control over financial reporting criteria established by the Company considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting issued by the Institute of Chartered Accountants of India.

For Agrawal Subodh & Co.
Chartered Accountants
Firms Registration No : 319260E
Subodh Kumar Agrawal
Place: Kolkata Partner
Date: 08th May, 2019. Membership No. : 054670

Annexure "B" to the Independent Auditors Report

(Referred to in paragraph 2 under ‘Report on Other Legal and Regulatory Requirements section of our report of even date)

i. (a) The Company has maintained proper records showing full particulars, including quantitative details and situation of !xed assets.

(b) The Company has a regular programme of physical veri!cation of its !xed assets by which all !xed assets are veri!ed in a phased manner over a period of three years. In accordance with this programme, certain !xed assets were veri!ed during the year and no material discrepancies were noticed on such veri!cation. In our opinion, this periodicity of physical veri!cation is reasonable having regard to the size of the Company and the nature of its assets.

(c) According to the information and explanations given to us and the records examined by us including registered title deeds, we report that, the title deeds, comprising all the immovable properties of land and buildings which are freehold, are held in the name of the Company as at the Balance Sheet date. In respect of immovable properties of land that have been taken on lease and disclosed as property, plant and equipment in the financial statements, the lease agreements are in the name of the Company, where the Company is the lessee in the agreement, except for one plot of leasehold land, which is in the process of being registered since 2010-11, the gross block and net block of which amounts to Rs.15.23 lacs and Rs.12.82 lacs respectively, as on 31st March, 2019.

ii. According to the information and explanations given to us, the inventory has been physically veri!ed during the year by the management. In our opinion, the frequency of such veri!cation is reasonable. The discrepancies noticed on veri!cation between the physical stocks and the book records were not material and have been dealt with in books of accounts.

iii. The Company has granted loans to 2 (two) companies listed in the register maintained under Section 189 of the Companies Act,2013. In our opinion

a) the terms and conditions on which the loans had been granted were not, prima facia, prejudicial to the interest of the company.

b) the borrowers have been regular in the payment of principal and interest as stipulated

c) there are no overdue amounts for more than 90 days from the due date of each such loans

iv. In our opinion and according to the information and explanations given to us, the Company has complied with the provisions of sections 185 and 186 of the Companies Act, 2013 in respect of grant of loans, making investments and providing guarantees and securities, as applicable.

v. In our opinion and according to the information and explanations given to us, the Company has not accepted any deposit from the public in accordance with the provisions of Sections 73 to 76 or any other relevant provisions of the Act and the rules framed thereunder. Accordingly, paragraph 3(v) of the Order is not applicable to the Company.

vi. We have broadly reviewed the cost records maintained by the Company pursuant to the Companies (Cost Records and Audit) Rules, 2014, as amended prescribed by the Central Government under sub-section (1) of Section 148 of the Companies Act, 2013, and are of the opinion that, prima facie, the prescribed cost records have been made and maintained.

vii. According to the information and explanations given to us in respect of statutory dues:

(a) The Company has generally been regular in depositing undisputed statutory dues, including Provident Fund, Employees State Insurance, Income Tax, Sales Tax, Service Tax, Customs Duty, Excise Duty, Value Added Tax, Goods and Service Tax, Cess and other statutory dues to the appropriate authorities during the year. There were no undisputed amounts payable in respect of Provident Fund, Employees State Insurance, Income Tax, Sales Tax, Service Tax, Customs Duty, Excise Duty, Value Added Tax, Goods and Service Tax, Cess and other statutory dues in arrears as at 31st March, 2019 for a period of more than six months from the date they became payable.

(b) Details of dues of Central Sales Tax, Service Tax, Excise Duty, Entry Tax and Value Added Tax which have not been deposited as on 31st March, 2019 on account of disputes are given below:

Particulars Financial year to which the matter pertains Forum where matter is pending Amount (र. in Lacs) Amount Unpaid (र. in Lacs)
The Central Excise Act, 1994 & Service Tax (Finance Act, 1994) 1994-95 ACCE 0.87
2008-09 to Oct2012 Comm. Appeals 0.07
2012-13 & 2014-15 Comm. Appeals 2.67 3.61
2006-07 Tribunal 110.64 74.81
Case to be !led before
2011-12 & 2012-13 CESTAT, Kolkata 9.09 8.18
2010-11 to 2012-13 Commissioner (A) BBSR 19.03 18.32
2011-12 CESTAT, Kolkata 4.46 3.67
2014-15 Assistant Commissioner 18.62 2.43
(CGST & Customs), Balasore
2014-15 Assistant Commissioner 45.76 5.97
(CGST & Customs), Balasore
Central Sales Tax 1993-94 Tribunal 20.26 16.26
2004-05 DCCT 1.99 0.53
2009-10 Comm. Appeals 19.62 17.12
2010-11 Tribunal (Cuttack) 2.58 1.88
2015-16 Tribunal (Cuttack) 2.17 1.15
2016-17 DCCT, Balasore 31.85 28.66
2017-18 Comm. Appeals 3.69 3.69
Value Added Tax 2006-07 Comm. Appeals 0.64 0.59
Act, (Orissa) 2009-10 Comm. Appeals 10.79 10.79
2011-12 Comm. Appeals 1.98 1.78
Orissa Sales Tax 1989-90 High Court 2.01 0.79
ESIC 1996-97 ESIC Court 0.25 0.22
Entry Tax Act 2013-14 High Court 89.39 81.29
(West Bengal) 2014-15 High Court 83.48 83.48
2015-16 High Court 82.42 82.42
2016-17 High Court 56.99 56.99
2017-18 High Court 14.28 14.28

viii. In our opinion and according to the information and explanations given to us, the Company has not defaulted during the year in repayment of loans or borrowings to financial institutions, bankers and the government. The Company did not have any outstanding debentures during the year.

ix. The Company did not raise any money by way of initial public o$er and further public o$er (including debt instrument). To the best of our knowledge and belief and according to the information and explanations given to us, term loans availed by the company were applied for the purpose for which the loans were obtained.

x. To the best of our knowledge and according to the information and explanations given to us, no fraud by the Company and no fraud on the Company by its Officers or employees has been noticed or reported during the year.

xi. According to the information and explanations given to us, the company has paid/ provided for managerial remunerations in accordance with the requisite approvals mandated by the provisions of Sec 197 read with Schedule V to the Act.

xii. In our opinion and according to the information and explanations given to us, the Company is not a Nidhi company. Accordingly, paragraph 3 (xii) of the Order is not applicable.

xiii. According to the information and explanations given to us and based on our examination of the records of the Company, transactions with the related parties are in compliance with sections 177 and 188 of the Act where applicable and details of such transactions have been disclosed in the Ind AS Financial Statements as required by the applicable Indian Accounting Standards.

xiv. According to the information and explanations given to us and based on our examination of the records, the company has not made any preferential allotment or private placement of shares or fully or partly convertible debentures during the year.

xv. According to the information and explanations given to us and based on our examination of the records of the Company, the Company has not entered into non-cash transactions with directors or persons connected with them. Accordingly, paragraph 3 (xv) of the Order is not applicable.

xvi. According to information and explanations given to us, the Company is not required to be registered under Section 45 IA of the Reserve Bank of India Act, 1934.

For Agrawal Subodh & Co.
Chartered Accountants
Firms Registration No : 319260E
Subodh Kumar Agrawal
Place: Kolkata Partner
Date: 08th May, 2019. Membership No. : 054670